Glory Dots Privacy Statement

Glory Dots Tech – Updated Privacy Policy

This privacy statement is effective as of June 2, 2023, and will be updated regularly to reflect any changes in how we handle your personal data or in applicable laws. Unless specified otherwise, this statement applies to all of Glory Dots Tech’s externally facing applications, services, tools, websites, and other data processing activities where Glory Dots Tech acts as a data controller (or any equivalent role).

This document, along with its sub-pages, provides comprehensive information on how Glory Dots Tech LLP and its affiliates, subsidiaries, and newly acquired companies (“Glory Dots Tech”; “we”) protect the personal data we process and control relating to you (“your personal data”; “your data”) and outlines your rights concerning this processing.

If the Glory Dots Tech entity responsible for your personal data is located outside the European Union and Switzerland, if applicable, Glory Dots Tech will represent it in data privacy matters.

Below is a general overview of how Glory Dots Tech protects your personal data, followed by specific details on the following:

      • How we use personal data when you visit Glory Dots Tech’s website
      • How we use cookies and other tracking technologies
      • How we use personal data when you visit our offices
      • How we use personal data for marketing purposes

How does Glory Dots Tech protect your personal data?

At Glory Dots Tech, your privacy and the protection of your personal data are of utmost importance. We want you to feel confident that when you interact with us, your personal data is handled with care.

Glory Dots Tech safeguards your personal data in compliance with applicable laws and our data privacy policies. Additionally, we implement appropriate technical and organisational measures to protect your data against unauthorised or unlawful processing, accidental loss, alteration, disclosure, access, or destruction.

The following sections provide more detailed information on how Glory Dots Tech processes your personal data:

      • Categories of personal data we collect and how we process them
      • Purposes and legal bases for using your personal data
      • Sharing your personal data with third parties
      • Handling sensitive data
      • Ensuring data security
      • Location of data processing
      • Retention period for your personal data
      • Your rights concerning the processing of your personal data

Categories of Personal Data We Collect and How We Process Them?

We collect personal data from employees, potential employees, clients and their current/former/prospective employees/directors, suppliers, business contacts, shareholders, and website users. If any data we collect is not listed in this privacy statement, we will provide individuals with appropriate notice, as required by law, regarding the data collected and its intended use.

The personal data we collect includes the categories described in the sections “How we use personal data when you visit Glory Dots Tech’s website,” “How we use cookies and other tracking technologies,” “How we use personal data when you visit our offices,” and “How we use personal data for marketing purposes,” as well as any other categories of personal data mentioned in this privacy statement or other notices you have received.

Below is a chart describing the categories of personal data we collect:

Category of Personal Information  | Types of Personal Information Captured by Category

Personal details, contact details, and identifiers | Name, pronoun, all types of identifiers and contact details (such as email, phone numbers, physical address), and occasionally gender, date of birth, age, place of birth.

Commercial information | History and records of the products and services you have obtained from Glory Dots Tech, and correspondence between you and us via dedicated mailboxes or other electronic communication means.

Marketing and research information | Identifiers like IP address, social media handle, or other online identifiers, demographic data, browser/web history data, social media content, analytics and profiles, and voice-enabled services.

Sensitive data and biometric information | Health/medical information, biometric information (e.g., fingerprint authentication). Audiovisual materials, including transcriptions | Photographs, images/footage captured on CCTV, or during marketing/public filming events, voice search functionality, and audio-video recording/transcription during meetings.

Position and professional or employment-related information | Professional or employment-related information like job title, employer, location, and contacts. System and application access data and Internet and electronic network activity information | Information required to access Glory Dots Tech systems and applications, including system passwords, access logs, activity logs, and electronic content produced using Glory Dots Tech systems.

Cookies and geolocation data | As described in our Cookies policy.

Glory Dots Tech alumni related information | Information provided when registering as a Glory Dots Tech alumnus/alumna, including name, email address, and other relevant details.

We collect the above-mentioned categories of personal data either directly from you (e.g., when signing up for a newsletter) or indirectly from certain third parties (e.g., through website technology or our affiliates, public authorities, and vendors). If you choose not to provide certain information, we may not be able to achieve some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems requiring such data.

Purposes and Legal Basis for Using Your Personal Data

Glory Dots Tech uses your personal data for specific purposes only. Please refer to the table below for the purposes and corresponding legal bases:

Purpose | Legal Basis

Managing our contractual and/or employment relationship with you | Necessary for the performance of a contract to which you are a party. Recruitment | Justified on the basis of our legitimate interests in recruiting suitable employees.

Where we rely on legitimate interests, we believe that these are not overridden by your interests, rights, or freedoms due to the transparency we provide, our privacy-by-design approach, regular privacy reviews, and the rights you have concerning the processing. If you require more information on this balancing test approach, please contact Glory Dots Tech’s Data Privacy Officer or write to us at info@glorydots.com

We will process your personal data for the aforementioned purposes based on your prior consent where required by applicable laws. By clicking “I accept,” “I agree,” or similar buttons or checkboxes in relation to a privacy statement, you provide your consent to process your personal information, where such consent is mandated by law.

We will not use your personal information for purposes that are incompatible with those you have been informed of unless required or authorized by law, or in cases of vital interest (e.g., medical emergencies).

Will we share your personal data with third parties?

Yes, we may share your personal data with our service providers, professional advisors, public and governmental authorities, Glory Dots Tech companies/affiliates, or other third parties involved in the operations of Glory Dots Tech. This includes instances where data is shared for corporate or commercial transactions, or for providing client services. These third parties might be located in other countries. Before sharing your data, we take necessary steps to ensure that it is protected according to relevant data privacy laws and Glory Dots Tech’s internal policies. Additionally, we may transfer your data to our global affiliates or partners, particularly in relation to your visits to Glory Dots Tech locations.

If you would like to know more about the categories of personal information we may share, please refer to the section titled “Which categories of personal data do we collect and how do we process such personal data?”

We may disclose personal information to third parties for various business purposes, such as:

      • Sharing your data with authorized third-party service providers for services including billing, payment processing, customer service, email deployment, advertising, marketing, security, performance monitoring, account maintenance, order processing, customer verification, research, data hosting, auditing, and data processing.
      • Protecting and defending the legal rights, safety, and security of Glory Dots Tech, our affiliates, users, or the public, including protection against fraud and malicious activity.
      • Other business purposes as described in this privacy statement or as disclosed to you at the time of data collection, or with your consent.
      • In the event of a significant corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of bankruptcy, your data may also be shared.

If your personal data is transferred from within the European Economic Area (EEA) to third parties outside the EEA, it will be based on an adequacy decision or governed by standard contractual clauses (a copy of which can be obtained through the contact information provided below). For any non-EEA related transfers, your data will be processed in accordance with appropriate international data transfer mechanisms and standards.

What about sensitive data?

We do not generally seek to collect sensitive data (also known as special categories within the EEA) through this site or by other means. In rare cases where we do collect such data, we do so in accordance with data privacy laws and/or with your explicit consent. “Sensitive data” refers to categories of personal data that require special treatment under data privacy laws, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, biometric or genetic data, sexual orientation, or criminal convictions.

What about data security?

We have implemented organizational, physical, and technical security measures to protect all personal data in our possession. These measures include protocols, controls, and policies designed to address the risks associated with the personal data we process. Our security practices include, but are not limited to:

      • Holding ISO27001 certification, which signifies adherence to the highest international information security standards.
      • Implementing a global Client Data Protection (CDP) program to govern the stewardship of client information and systems.
      • Conducting regular third-party penetration testing to ensure the strength of our technical defences.

Where will your personal data be processed?

As a global organisation, the personal data we collect may be transferred or accessible internationally across Glory Dots Tech’s global business and entities. Any such transfers occur in compliance with applicable data privacy laws and our Binding Corporate Rules (BCR), which reflect European data privacy standards. Your rights under our BCR remain consistent, regardless of where your data is processed within Glory Dots Tech.

What are the sources of your personal information?

If we do not collect your personal information directly from you, we may obtain it from publicly available sources, Glory Dots Tech employees, contractors, board members, shareholders, affiliates, subsidiaries, newly acquired businesses, public authorities, websites, social media, previous employers, educational institutions, suppliers, and vendors.

How long will we retain your personal data?

We retain your personal data only as long as necessary. Our records management and retention policies ensure that data is deleted after a reasonable period based on the following criteria:

      • We retain your data as long as we maintain an ongoing relationship with you, such as if you have an account with us.
      • We retain data while your account is active or as long as necessary to provide services to you.
      • We retain data to comply with global legal and contractual obligations.

Which rights do you have regarding your personal data?

You have the right, under certain conditions and exceptions, to:

      • Request access to your personal data and obtain information or a copy of the data we hold.
      • Request rectification of inaccurate or incomplete personal data.
      • Object to the processing of your personal data.
      • Request erasure of your personal data when it is no longer necessary for the purposes for which it was collected.
      • Request the restriction of processing under certain circumstances.
      • Request portability of your personal data in a structured, commonly used, and machine-readable format.

If you wish to withdraw your consent for data processing, you may do so at any time by contacting Glory Dots Tech’s Data Privacy Officer. This will not affect our right to process data obtained before your withdrawal or to continue processing based on other legal bases.

If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority or pursue legal action in a competent court. However, we encourage you to contact us first to resolve any issues.

How do we use personal data when you visit Glory Dots Tech’s website?

We collect personal data on our website in two ways: directly (e.g., when you sign up for a newsletter) and indirectly (e.g., through website technology). This data may include information provided through forms, correspondence, surveys, postings, or automatically collected data such as IP addresses and browser details. We use this data to improve our website, analyze traffic, and provide relevant user experiences.

How do we use cookies and other tracking technologies?

We use cookies and tracking technologies to analyze IP and browser information, determine website effectiveness, and improve user experiences. For more information, please refer to our Cookies policy.

How do we use personal data when you visit our offices?

When visiting our offices, we process your personal data according to this privacy statement, with specific information provided regarding visitor data and CCTV use.

How do we use personal data for marketing purposes?

We may collect personal data for marketing purposes from public sources, including social media, to establish or maintain business relationships. We send targeted emails that may include web beacons, cookies, and similar technologies to track engagement. You can manage your preferences or opt-out at any time.

How else might we use your personal data?

In addition to the above, some authorized Glory Dots Tech entities may process personal data for content creation/production activities, such as TV, film, marketing, or advertising. This may include images, footage, location data, and other relevant information.

Contact us

For any inquiries about how Glory Dots Tech protects your personal data or to exercise your rights, please contact us.